Persons who, within the work context, have become aware of violations of the prescriptions contained in Model 231, the Code of Ethics and related company procedures and, in general, of violations regarding national or European Union regulatory provisions that harm the public interest or the integrity of Gemelli Isola may report such violations to the Supervisory Board (SB), in a timely and detailed manner. Those wishing to make a Report must specify that it is a Report for which they intend to keep their identity confidential and benefit from the protections provided by the Whistleblowing Law in terms of protection from possible retaliation.
Reports can be made, in written form, using the following internal channels:
- Computer platform, accessible through the button below (“insert your report”) and which is the preferred channel due to its security and confidentiality features for the protection of the Whistleblower;
- Ordinary mail, addressed to the Supervisory Board and to be delivered to Via di Ponte Quattro Capi 39, 00186 Rome (RM), to the attention of the General Management. Should the Report concern a member of the Supervisory Board, it should be addressed to the Internal Audit Function, to be delivered to Via di Ponte Quattro Capi 39, 00186 Rome (RM), to the attention of the Head of the Function.
The Report must be placed in two sealed envelopes: the first with the identifying data of the Reporting Party together with a photocopy of the identification document; the second with the Report, so as to separate the identifying data of the Reporting Party from the Report. Both should then be placed in a third sealed envelope bearing on the outside the words “confidential” to the manager of the Reporting (e.g., “confidential to the Supervisory Board”). The Report is then subject to confidential protocol, also by means of an autonomous register, by the manager.
For Reports under point 2, the reporting party is required to use the appropriate form that can be downloaded from the company intranet.
Reports can also be made orally, using the following channel:
- Making an appointment for a direct meeting with the SB, through one of the channels mentioned in the above points. Should the Report concern a member of the SB, an appointment with the Head of the Internal Audit Function may be requested.
For all communication channels, Gemini Isola adopts appropriate organizational and IT measures in order to ensure maximum security and confidentiality of the Reporting Party, the person involved and the person in any way mentioned in the Report, as well as the content of the Report and the related documentation. To this end, the IT platform and the data contained therein are managed by a company external and independent of the Company, which, for its use, does not provide for registration requirements. Therefore, through the platform, like other channels, Reports can also be transmitted anonymously, provided they are adequately substantiated and detailed.
The processing of personal data related to the receipt and management of Reports is carried out by Gemini Isola as the Data Controller, in compliance with European and national principles on the protection of personal data.
By clicking on “enter your report” you access the computer platform for sending a Report.
In the cases referred to in Article 6 of Legislative Decree 10/03/2023, No. 24, specified below, the Reporting Party may make an external Report to ANAC through the channels available on the website www.anticorruzione.it/-/whistleblowing. In particular:
- If the mandatory internal channel:
- Is not active;
- Is active but does not comply with the provisions of the legislature regarding the subjects and methods of submission of Reports;
- The person has already made the Internal Reporting but it has not been followed up;
- The Reporting Person has reasonable grounds to believe that if he/she made an Internal Reporting:
- The same would not be effectively followed up;
- This could result in risk of retaliation;
- The Whistleblower has reasonable grounds to believe that the violation may pose an imminent and obvious danger to the public interest; and
For more information on the process of entering and managing Whistleblowing Reports and the use of the platform, it is suggested to consult the Procedure on the Whistleblowing Management System and the FAQs, respectively.
For more information on the rights of the whistleblower and how to report, please refer to the current legislation and the Guidelines issued by ANAC at the following link: www.anticorruzione.it/-/whistleblowing
Click on “enter your report” to access the computer platform for submitting a Report.
